ph365.com Privacy Policy

1. Introduction

ph365.com ("ph365.com," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the ph365.com platform ("Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

This Privacy Policy applies to all personal data collected through the ph365.com website, mobile applications, customer support channels, and any other touchpoints through which you interact with ph365.com. By registering for an account or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions, which govern your use of the ph365.com Platform.

2. Personal Data We Collect

ph365.com collects the following categories of personal data from users of the Platform:

We collect only the minimum personal data necessary for the purposes described in this Policy. We do not collect sensitive personal information (as defined under the DPA) unless strictly required by law or with your explicit consent.

3. How We Collect Your Data

ph365.com collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or responding to surveys and promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs.
• Third-party sources: Identity and fraud-screening data from licensed KYC/AML service providers; payment data from GCash, Maya, and partner banks; and analytics data from platform performance tools — all subject to their respective privacy policies and our data processing agreements with them.

4. How We Use Your Personal Data

ph365.com uses the personal data we collect for the following purposes:

• To create, verify, and manage your ph365.com account.
• To process deposits, withdrawals, and other financial transactions on the Platform.
• To verify your identity and age (21+) in compliance with Philippine gaming regulations.
• To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations under Philippine law.
• To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct.
• To personalize your gaming experience and deliver relevant promotions and offers.
• To monitor your gaming activity for responsible gaming purposes and to enforce self-exclusion or deposit limit requests.
• To communicate with you regarding your account, transactions, promotions, and platform updates.
• To analyze Platform usage and improve our products, services, and user experience.
• To comply with applicable laws, regulations, and orders from competent Philippine authorities.

5. Legal Basis for Processing

ph365.com processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given clear, informed consent to the processing of your personal data for a specific purpose (e.g., receiving marketing communications).
• Contractual necessity: Where processing is necessary to perform our obligations under the Terms & Conditions you have agreed to, including account management and transaction processing.
• Legal obligation: Where processing is required to comply with applicable Philippine laws and regulations, including gaming regulations, AML/CTF laws, and tax obligations.
• Legitimate interests: Where processing is necessary for our legitimate business interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and freedoms.

6. Data Sharing & Disclosure

ph365.com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, Maya/PayMaya, and partner Philippine banks, for the purpose of processing your deposits and withdrawals.
• KYC/AML service providers: Licensed identity verification and fraud screening providers engaged to assist with regulatory compliance.
• IT and platform service providers: Cloud hosting, cybersecurity, and analytics vendors who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where disclosure is required by law or court order.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

Any third party with whom we share your data is required to handle it in accordance with applicable Philippine data protection laws and our contractual requirements.

7. Cookies & Tracking Technologies

ph365.com uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming limits you have set.
• Analytics cookies: Help us understand how users interact with the Platform — which pages are visited most, where users encounter errors, and how we can improve performance. Data collected is aggregated and anonymized.
• Marketing cookies: Used to deliver relevant promotions and measure the effectiveness of our campaigns. These are only set with your consent.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the ph365.com Platform.

8. Data Retention

ph365.com retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations and PAGCOR requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act (R.A. 9160, as amended).
• Customer support communications are retained for three (3) years from the date of the interaction.
• Marketing consent records are retained for as long as you remain a registered user, and for two (2) years following account closure.

When personal data is no longer required for any lawful purpose, ph365.com will securely delete or anonymize it in accordance with our data disposal procedures.

9. Data Security

ph365.com implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the ph365.com Platform.
• AES-256 encryption for sensitive data stored on our servers.
• Multi-factor authentication options for account access.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Role-based access controls ensuring that only authorized personnel can access personal data, strictly on a need-to-know basis.
• Continuous monitoring of our systems for suspicious activity and potential security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph365.com will notify the National Privacy Commission and affected users in accordance with the timeframes and procedures prescribed under the DPA and NPC Circular No. 16-03.

10. Your Rights Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph365.com:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: You may request a copy of the personal data ph365.com holds about you, along with information about how it is being used.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 13 of this Policy. We will respond to all verified requests within fifteen (15) business days, as required under the DPA.

11. Children's Privacy

The ph365.com Platform is strictly intended for users who are 21 years of age or older, in accordance with Philippine gaming regulations. ph365.com does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on ph365.com or provided us with their personal data, please contact us immediately so we can take appropriate action.

12. Changes to This Privacy Policy

ph365.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or regulatory requirements. When we make material changes, we will notify registered users by email and/or by posting a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how ph365.com is protecting your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by ph365.com, please contact our designated Data Protection Officer (DPO):

• Data Protection Officer: ph365.com Privacy Team
• Email: [email protected]
• Live Chat: Available 24/7 via the ph365.com Platform
• Postal Address: ph365.com Data Privacy Office, Metro Manila, Philippines

We aim to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within fifteen (15) business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.